How Ascent360 defines email permission for contacts under CASL

Email contacts that are known Canadians will be processed under Canadian Anti-Spam Law (CASL) rules. 

Identifying CASL Applicable Individuals

Ascent360 identifies individuals as Canadians if they have a known address in Canadian territory or if they have a “.ca” email address.

Here's how their email permission is determined:

  • If they have explicitly subscribed or unsubscribed, Ascent360 considers this a “explicit” email permission and the subscriber will remain with that email permission status unless they change it. 
  • If they have never explicitly subscribed or unsubscribed, we consider this a “implicit” email permission. If they have made a purchase within the last 23 months, we consider them contactable, or a “soft” yes because there is an implied business relationship due to the financial transaction. This allows them to be contacted by email for up to two years after the transaction.
  • If their last financial purchase was more than 23 months ago, they are no longer considered contactable and we treat them as a “implicit” unsubscribe.
  • Similarly, if an implicit opt-in or opt-out explicitly unsubscribes or subscribes, their subscription settings change to a explicit no or explicit yes.

Last Financial Purchase Date

Current Email Permission

Explicit No

Explicit Yes

Implicit Yes

Implicit No

23+ months ago

Not contactable


Becomes Implicit No and not contactable

Not contactable

Less than 23 months ago

Not contactable



Becomes Implicit Yes and contactable

Please note: If any transaction data, specifically around a financial purchase date, was not being sent to Ascent360 correctly, that would impact the customer’s email permission for any contacts being processed under CASL rules. Because of this, a lack of transaction data will result in a higher percentage of implicit unsubscribes.